POSCO A&C operates the checklist for law violation by type, which reflects the business characteristics.
Major Issue Disclosure System including Non-Listed Companies
Items to Inspect | Checklist |
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Governance (Article 11.3 of the Fair Trade Act) |
Status and change of major issues related to governance
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Financial Structure (Article 11.3 of the Fair Trade Act) |
Issues causing changes in financial structure
|
Business Activities (Article 11.3 of the Fair Trade Act) |
Issues causing changes in company’s business activities.
|
Unjust Support Activity (Unjust Insider Trading)
Items to Inspect | Checklist |
---|---|
Unjust Fund Support (Article 23 of the Fair Trade Act) |
Activity supporting the affiliate person or another company by offering excessive economic profit
|
Unjust Manpower Support (Article 23 of the Fair Trade Act) |
An activity supporting an affiliate person or another company by offering excessive economic
|
Unlawful Asset Support (Article 23 of the Fair Trade Act) |
An activity supporting an affiliate person by offering excessive economic profit through offering
|
Unfair Subcontracting Transaction (Obligations of General Contractor)
Items to Inspect | Checklist |
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Issuance in Writing (Article 3 of the Subcontracting Act) |
A document containing certain matters shall be issued to the subcontractor in advance, unless
|
Document Preservation (Article 3 of the Subcontracting Act) |
The general contractor shall preserve certain documents on subcontracting transactions.
|
Payment of Advanced Payment (Article 6 of the Subcontracting Act) |
The general contractor shall pay the advancement payment to the subcontractor within 15 days
|
Standard, Method and Period of Inspection (Article 9 of the Subcont- racting Act) |
Except for legitimate reasons, the general contractor shall notify the subcontractor of the insp-
|
Payment of Subcontract Cost (Article 13 of the Subcontracting Act) |
The subcontract cost shall be paid until the payment date set with short period of within 60
|
Subcontract Cost Adjustment According to Change Order (Article 16 of the Subcon- tracting Act) |
If the general contractor receives additional money from the client, due to change order or eco- Is it an activity through which the general contractor does not pay or pays less than the ratio or |
Unfair Subcontracting Transactions (Prohibitions Against General Contractor)
Items to Inspect | Checklist |
---|---|
Decision on Unfair Subcontract Cost (Article 4 of the Subcon- tracting Act) |
Decision of subcontract cost at lower level than usually paid on the same type or similar one as
|
Prohibition of Coerced Purchase of Goods (Article 5 of the Sub- contracting Act) |
The general contractor shall not coerce the subcontractor to buy goods and equipment design-
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Prohibition of Unjust Payment Request includ- ing Goods Purchase Cost (Article 12 of the Subcon- tracting Act) |
In case the general contractor lets buy its goods or equipment necessary for manufacturing of
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Prohibition of Unjust Reduction of Amount (Article 11 of the Subcon- tracting Act) |
Unjust reduction of subcontract cost shall not be made, when manufacture is commissioned,
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Prohibition of Unfair Intervention in Manage- ment (Article 18 of the Subcon- tracting Act) |
The general contractor shall not intervene in the subcontractor’s management using a method
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Prohibition of Retaliation (Article 19 of the Subcon- tracting Act) |
The general contractor shall not undertake an action limiting order winning opportunity, suspe-
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Behavior Rules to Prevent CARTELS
First, meeting competitors may arouse suspicion as a cartel.
- Because rival companies are not partners but competitors, meeting them should be avoided to prevent any misapprehension.
- Contacting competitors for simply collecting information may also cause misapprehension.
Second, do not consult about prices and market trends in gatherings including business group meetings.
- Do not discuss anything that may cause misapprehension, including prices and market trends, even during the government’s
administrative guidance.
Third, you have to clearly express an objection to any behavior that may arouse suspicion of a cartel even during unavoidable
contact.
- It is necessary to express your opposite intention so as to demonstrate it subsequently and take follow-up measures after
consulting with experts.
Fourth, do you review whether external PR materials include any contents against laws in advance?
- It is necessary to examine PR materials that may influence prices in advance, including price increase and change to the status
of supply and demand.
Fifth, it is essential to deal with tasks and prepare documents based on the compliance program (CP).
- It is better to always clarify sources of information in relation to competitors.